Requests for Admission are a vital discovery tool, but knowing exactly how to draft them can be challenging. Sample RFAs give litigators a blueprint to craft precise, targeted requests that maximize admissions and minimize objections.
Requests for Admission (RFAs) play a pivotal role in streamlining civil litigation by requiring parties to formally admit or deny specific statements, whether about factual events, the authenticity of documents, or legal issues relevant to the case. By securing admissions on uncontested points early, RFAs help narrow the issues that must be tried, saving time, reducing costs, and focusing litigation efforts on genuinely disputed matters.
Well-crafted RFAs are invaluable for laying the groundwork for dispositive motions, such as motions for summary judgment, by establishing key facts that the opposing party cannot reasonably deny. They can also simplify trial preparation by eliminating the need to prove undisputed facts at trial, thus reducing complexity and uncertainty.
However, drafting effective RFAs demands careful thought and precision. Poorly constructed requests—those that are vague, ambiguous, compound, or overly broad—are prone to objections, evasions, or outright denials. Such weaknesses can undermine your discovery strategy by creating unnecessary disputes, delaying progress, and potentially weakening your position before the court.
To avoid these pitfalls, it helps to study sample RFAs tailored to common civil litigation scenarios. These examples demonstrate how to phrase requests clearly and purposefully to maximize the likelihood of admission while minimizing objections. They also illustrate how to link requests directly to the relevant facts and legal issues in your case.
In this article, we will provide:
• ✅ Practical sample RFAs organized by key civil litigation topics, including contract disputes, personal injury, employment law, and real estate cases.
• ✅ Tips on how to adapt these sample requests to the specifics of your case and jurisdictional rules.
• ✅ Advice on avoiding common drafting mistakes and handling responses effectively to maintain control of your discovery process.
Mastering the art of drafting RFAs can significantly improve your litigation strategy by clarifying issues early and strengthening your position throughout the case.
Requests for Admission in contract disputes are designed to establish the fundamental facts that form the basis of the parties’ legal claims or defenses. These requests often focus on verifying the existence and terms of the contract, confirming performance or breach, and establishing whether proper notices were given. Using clear, targeted RFAs helps streamline issues related to contract formation, breach, and damages, making it easier to prove your case or narrow the trial issues.
Here are some commonly used RFAs tailored for contract disputes:
Admit that you entered into a written contract with [Plaintiff/Defendant] on or about [Date].
This request establishes the existence of a contract and the timing of the agreement, which is foundational to the dispute.
Admit that the document titled “[Contract Name]” is a true and accurate copy of the contract between the parties.
This verifies authenticity and avoids later disputes over document validity.
Admit that you failed to perform the obligations described in Section [X] of the contract.
This request targets specific contract duties that are alleged to have been breached, providing a clear admission or denial on essential elements.
Admit that you received written notice of breach on or about [Date].
Notices of breach are often required under contract terms or by law; this RFA confirms the opposing party’s awareness of the alleged default.
Admit that no payments were made to [Plaintiff/Defendant] after [Date].
This helps establish damages or non-performance related to payment obligations.
💡 Tip:
For maximum impact, each request should be closely tied to a key legal element of your claim or defense—such as contract formation, breach, notice, or damages. This specificity makes it easier for courts to see the relevance of each admission and reduces room for objections based on relevance or overbreadth. Tailoring requests in this way also helps ensure that admissions you obtain will support dispositive motions or streamline trial preparation.
In personal injury litigation, Requests for Admission serve as powerful tools to confirm basic facts about the incident, the parties’ involvement, and the evidence that will underpin liability and damages claims. These RFAs help to narrow disputes by securing admissions on critical points such as presence, actions, and the authenticity of evidentiary materials. Establishing these facts early in the discovery process can significantly reduce contested issues at trial and support motions for summary judgment.
Below are examples of commonly used RFAs in personal injury cases:
Admit that you were present at the scene of the incident on [Date].
This request confirms the party’s physical presence at the location where the injury occurred, establishing a key factual predicate.
Admit that you were the operator of the vehicle involved in the accident on [Date].
Identifying who controlled the vehicle is crucial for assigning responsibility and liability.
Admit that the photographs attached as Exhibit A are true and accurate representations of the accident scene.
This request authenticates photographic evidence, preventing disputes over whether images accurately depict the scene.
Admit that you failed to stop at the traffic signal located at [Intersection] on [Date].
Such requests directly address alleged negligent conduct, which is often central to liability.
Admit that you did not seek medical treatment until [Date].
This admission can impact damage claims by establishing timelines for injury recognition and treatment delays.
💡 Tip:
Use Requests for Admission strategically to lock in uncontested liability facts and authenticate critical evidence as early as possible. This approach simplifies your case presentation and puts pressure on the opposing party to respond truthfully or risk adverse inferences. Precise RFAs prevent evasive answers and create a foundation for stronger settlement negotiations or dispositive motions.
Employment disputes often hinge on verifying the basic facts of the employment relationship, workplace policies, disciplinary actions, and claims of discrimination or retaliation. Requests for Admission in these cases can help establish undisputed facts about the employment timeline, adherence to company procedures, and the employee’s conduct. By obtaining admissions on these foundational points, litigators can narrow the issues that require proof at trial and strengthen their overall case strategy.
Consider these common RFAs in employment litigation:
Admit that you were employed by [Company] from [Start Date] to [End Date].
This request confirms the existence and duration of the employment relationship, a critical baseline fact for any employment dispute.
Admit that you signed the employee handbook dated [Date].
Establishing that the employee acknowledged company policies and procedures is important for disputes involving workplace rules or conduct standards.
Admit that you received written warnings regarding performance or conduct on the following dates: [List Dates].
This helps document disciplinary history and counters claims of unfair treatment or retaliation by showing prior notice.
Admit that you were denied a promotion on or about [Date].
Confirming denial of advancement supports claims related to discrimination, retaliation, or breach of contract.
Admit that you did not file any formal complaints about discrimination prior to [Date].
This request can be critical for defense strategies, as timely reporting often affects the viability of discrimination or retaliation claims.
💡 Tip:
Draft RFAs in employment disputes to pinpoint the employee’s work history and interactions with company policies. Clear, focused admissions can dispel ambiguity about what actually occurred in the workplace and prevent the case from being sidetracked by unnecessary factual disputes.
Admit that you own the property located at [Address].
Admit that the attached document labeled Exhibit B is a true and correct copy of the deed to the property.
Admit that you granted a lease to [Tenant Name] commencing on [Date].
Admit that you failed to maintain the property in a habitable condition as required by law.
Admit that you received the notice of eviction dated [Date].
💡 Tip: Focus on ownership, agreements, and condition issues to reduce factual disputes.
Customize samples to fit your jurisdiction’s rules and case specifics.
Avoid compound or ambiguous language to reduce objections.
Prioritize requests tied to key issues that can significantly narrow trial scope.
Use RFAs to authenticate documents, saving time at trial.
Remember to serve responses on time and follow up on evasive answers promptly.
Q1: Can I use RFAs to ask about legal conclusions?
Yes, but courts often scrutinize legal conclusion RFAs closely. Use them sparingly and focus more on facts.
Q2: What happens if a party refuses to admit or deny?
The party must state why it cannot admit or deny, usually due to lack of information. Challenge vague responses if warranted.
Q3: How many RFAs should I serve?
Check your jurisdiction’s limits; excessive requests may be objected to as burdensome.
Sample Requests for Admission offer a roadmap to mastering this powerful discovery tool. By tailoring clear, relevant requests to your case’s unique facts and legal issues, you can reduce trial complexity, clarify your opponent’s position, and gain strategic advantages.
✅ Need help drafting effective discovery requests for your case?
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• Draft precise and compelling RFAs
• Respond strategically to discovery objections
• Manage discovery efficiently to control costs and deadlines
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